Memorandum

TO: Portland Cement Project Team
FROM: Keith Barnett, US EPA
SUBJECT: Revised Floors without Kilns that Would have been CISWI Kilns Had the Solid Waste Definition Applied
DATE: April 25, 2011
Revision of Emission data base to remove possible CISWI kilns The following table lists kilns that had been identified as potential CI SWIkiln s in the proposal of the CI SWIrule. This list w a s compiled based on responses to an EPA survey an d was based on the proposed definition of non

- hazardous solid waste.

Table 1. List of CISWI Cement Kilns at Proposal of the CISWI

Rule AL CemexDemopolis ALLafargeRobertaPlant ALLehighCementCoLeeds CACAPortlandCementColton CAL ehighSouthwestReddingPlant CAMitsubishiCement CANationalCementofCA FL CemexBrooksville FL CemexMiami FLFloridaRock FLRinkerBrooksville GACemexClinchfield IA LafargeBuffalo IA LehighCementMasonCity ID AshGroveInkom ILBuzziUnicemOglesb y ILLafargeJoppaPlant KSMonarchCementCoHumboldt MDESSROCFrederickPlant OKLafargeTulsaPlant OKLoneStarPryor ORAshGroveDurkee PAEssrocItalcementiGroupBessemerPAL afargeWhitehallPlant

PAL ehighCementEvansville PAL ehighCementYork SCLafargeHarley

ville TNCemexKnoxville TXAshGroveMidlothian TXCemexBalconesPlant TXHolcimMidlothianPlant TXL oneStarMary

neal UTAshGroveLeamington UTHolcimDevilsSlide WAAshGroveSeattle WAL afargeSeattle

Follow up questions were sent by EPA to these facilities to gain additional information on some of their fuels, specificall y used oil, tires, wood waste and spent seed corn. These responses were then reviewed based on the final solid waste definition rule signed on February 21 , 2011 . The final solid waste rule states that tires that come from an established tire collection p rogram, clean wood, clean biomass, and used oil that is on spec are not solid waste

. We eliminated the kilns that burned only

these alternative fuels f

rom the CISWI list. The remaining CISWI kilns are shown below in Table 2.

Table 2. CISWI Cement Kilns FacilityID UnitID Lehigh Southwest , Redding CA In

- Line Kiln/Raw Mill (S260) Cemex , Miami FL Cement Kiln Lafarge , Buffalo IA Kiln 1 Lehigh Cement , Mason City IA 302.203 Lafarge , Whitehall PA Kiln 2 Lafarge , Whitehall PA Kiln 3 Lehigh Cement , Evansville PA 122 Lehigh Cement , Evansville PA 121 Lehigh Cement , York PA 200 Holcim , Midlothian TX Kiln 2 Holcim , Midlothian TX Kiln 1 Holcim , Devils Slide UT Kiln 1 Ash Grove Cement, Midlothian TX Kilns 1 through 3 California Portland Cement, Colton CA Kilns 1 and 2In addition to the kilns above, the recent ICR follow up on alternative fuels indicates the

following kilns in Table 3 would also be CI SWI kilns (though they were not in the CI SWIdata base).
Table 3. Additional Kilns identified as CISWI Units (but are not in CISWI data base) Location Number of Kilns Why is it CISWI? Lehigh, Union Bridge MD 1 Burns dried biosolids as a fuel Lafarge, Alpena MI 5 Burns Plastics

Note that it is EPA’s position that combustion does not occur in the cold end of a cement kiln. Materials that enter the cold end of the kiln are gradually heated until they

reach the temperature where clinker formation takes place. This is in contrast to combustion where fuel is introduced into the kiln at a location where the temperature is sufficient to immediately commence the process of combusting the fuel. (Fuels are never burned in the cold end of a cement kiln, and our interpretation reflects that understanding.) This means that cement kiln s’ practices of using non - hazardous secondary materials in the cold end of the cement kiln would not make the kilns “solid waste incineration unit [s] ” within the meaning of section 129 (g)(1) of the CAA since kilns would not “combus[t]” th ose material s . Consequently , we do not include any cement kiln in this analysis based on utilization of non

- hazardous secondary materials in the cold end of the cement kiln

. For purposes of this analysis, all of the kilns shown in Tables 2 and 3 were taken out of the Portland cement emissions data base an d the floors recalculated as shown below. That is, we recalculated the floors as if the recently promulgated definition of non

- hazardous secondary materials which are solid wastes had been in place at the time of the cement kiln NESHAP rulemaking. Mercury Floor The mercury

floor was calculated based on a data base of 89 kilns where we had approximately 30 days of data on all mercury inputs. Twenty- two o f the 23 C IS WIkiln s shown above were part of the mercury data base. Removing the 22 CI SWIkiln s leaves 67 kilns. The best performing 12 percent would be 9 kilns. Of the best performing 11 kilns that were used in the previous floor calculation , two would have been CIWSI , 1589, and 1248. Removing the s e kiln s f rom the MACT floor pool leaves the 9 best performing kilns. The single best performing kiln now becomes kiln 1650.
The floors were recalculated (See attachment 1) based on the best performing 9 kilns and the new source floor was recalculated based on kiln 1650. The results were as follows: Existing Source floor: 58 lb/MM tons clinker (versus 55 in the current rule) New Source Floor: 24 lb/M tons clinker (versus 21 in the current rule)THC Floor

The THC Floor was re - estimated using the THC data set used in the final rule. This data set (shown in Attachment 2) consisted of 15 kilns where we had continuous monitoring data

. Of these 15 kilns, four would have been CI SWIkilns (including Union Bridge, the best performer on average) . This leaves 9 kilns (see attachment 3) , and the best 12 percent would be two. The best performing kilns on average become Suwannee, Branford and Holcim Trident. The resulting floor based on the 99th percentile of the data of the two flo or kilns is 15 ppmvd and the new source floor would be 11 ppmvd (see attachment 4 )

. The corresponding organic HAP limits (under the alternative standard) would be 6 and 4 ppmvd respectivel y.
P M Floor
There were 45 kilns in the PM data set used in the final rule (see attachment 5 ). Removing the CI SWI kilns left 28 kilns (see attachment 6 ). The best performing kilns would be the top 4. N ew source MACT does not change ; it is still the Mitsubishi kiln. The existing source MACT floor using the four best performing kilns is 0.05 lb/ton clinker (See Attachment 7 )

. HCl Floor
There were HCl test data for 2 0 major source kilns used in the final rule (see attachment 8 )

. Four of the 2 0 were CSWIkilns, leaving 1 6 NESHAP kilns (see attachment 9 ) . The best performing 12 percent would be 2. Recalculation of the floor based on the two best performing kilns results in a floor of 1 ppmvd (see attachment 10 ), which is still below the minimum quantification limit of 3 ppmvd

. This standard thus would remain at 3 ppmvd for new and existing sources.